This is an important new development. The Sierra Club is the oldest and
most influential and main stream environmental group in the United States.
They have put together a compelling case for suspending the approvals
for neonicotinoids until the safety for honey bees has been reassessed.
While their letter is addressed to the US-EPA, the scientific evidence
presented should be helpful to all of us, as we are making our case at
the EU and the member state level.

Re: Request to suspend use of nicotinyl insecticides until EPA obtains
scientific evidence that sublethal effects do not cause harm to
America's honey bees.

Dear Mr. Britten:

The Sierra Club and its 1.3 million members and supporters is
requesting that EPA's Office of Pesticide Programs (OPP) take urgent
action to suspend use of the high volume pesticides known as the
nicotinyl insecticides until the EPA possesses the scientific evidence
to demonstrate that these pesticides do not cause or contribute to
sublethal effects on the nation's honey bees. Serious questions need
to be raised by EPA's OPP over the sublethal effects to honey bees
occurring in the low parts per billion range (ppb) of 1.0 ppb to 20
ppb from these pesticides, which apparently the EPA has not evaluated
to date, and the pesticide manufacturer's may not have adequately
investigated or may have submitted incomplete findings to EPA.
Synergistic effects may also be occurring. The EPA has clearly missed
the unintended consequences of the nicotinyl (neonicotinoid)
insecticides, including imidacloprid, thiamethoxam, clothianidin, and
several others and now action is critical.

Without prompt EPA regulatory action to suspend use of the nicotinyl
pesticides (also known as neonicotinoids), the mounting economic
devastation to the nation's commercial honey bee operations and
agriculture will reach into billions of dollars and will irreversibly
harm beekeepers and farmers beyond their ability to make a recovery
not to mention the huge losses in the fruits and vegetables available
for consumers. The EPA's OPP surely is cognizant that federal agencies
in France and Germany have already taken responsible regulatory
actions to suspend use of these pesticides based on the best available
scientific evidence since at least 2002-3. Preliminary evidence was
available earlier in France, but EPA's OPP is moving too slowly to
take action to suspend nicotinyl pesticides.

The public is seriously concerned that the EPA lacks the necessary
scientific evidence to demonstrate the safety of sublethal doses of
the neonicontinoids that honey bees are being routinely exposed to
during their foraging activities in the US. Your Office of Pesticide
Programs is charged with properly implementing the Federal
Insecticide, Fungicide, and Rodenticide Act (FIFRA) for legal
authorization to allow various pesticide applications and it appears
that EPA's OPP is not diligently carrying out its duties under FIFRA
to the public and agriculture. More than one hundred and sixty Section
18 FIFRA emergency exemptions have been approved by EPA's OPP since
1997 without evaluating sublethal effects.

As EPA knows, additional large losses of honey bee colonies continue
to be widely reported by beekeepers in the United States into 2008 in
approximately forty agricultural producing states where fruit and
vegetable crops rely on honey bees for pollination and major crop
production. Fruit and vegetable losses have been reported by American
farmers as a growing agricultural crisis because honey bee colonies
have been collapsing in those regions.

EPA's OPP has either inadequately evaluated or totally failed to
evaluate the risks from sublethal effects due to low ppb range
exposures of the neonicotinoids on honey bees. Following is
information primarily from Germany and France where federal agencies
have taken responsible regulatory actions to suspend use of
neonicontinoids due to the growing scientific evidence of sublethal
effects on honey bees. The EPA should be acting responsibly to collect
as much scientific evidence as possible considering that the
information is publicly available from scientists in Germany and
France who have already conducted the research and collected the
evidence to warrant suspending neonicotinoids.

As EPA's OPP is aware, the German federal government Office for
Consumer Protection and Food Safety (BVL) ordered the immediate
suspension of the approval for eight seed treatment products due to
the mass death of bees in Germany's Baden-Wuerttemberg state. The
suspended pesticide products are mainly neonicotinoids:

1) Antarc
(ingredient: imidacloprid; produced by Bayer)

2) Chinook (imidacloprid; Bayer)

3) Cruiser (thiamethoxam; Syngenta)

4) Elado (clothianidin; Bayer)

5) Faibel (imidacloprid; Bayer)

6) Mesurol methiocarb; Bayer) and

7) Poncho (clothianidin; Bayer)

According to the German Research Centre for Cultivated Plants, they
reported that 29 out of 30 dead bees it had examined had been killed
by contact with the neonicotinoid clothianidin. Wild bees and other
insects are also suffering from a significant loss of population. In
communications with German beekeepers, Manfred Hederer, president of
the German Professional Beekeeper's Association reported that 50 to 60
percent of the bees have died on average, and some beekeepers have
lost all their hives. Beekeepers and agricultural officials in Italy,
France and Holland all noticed similar phenomena in their fields when
planting began in April and May.

In France most applications of imidacloprid were already banned in
1999. In 2003 the federal government science committee called Comit'
Scientifique et Technique, convened by the French government, declared
that the treatment of seeds with the neonicotinoid imidacloprid
produces a significant risk for bees. Only a few months ago Bayer's
application for the pesticide clothianidin was rejected by French
authorities. French research teams have published scientific evidence
that they identified several of these neonicotinoid pesticides in low
parts per billion concentrations throughout the plant tissues and
organs well beyond the root system, and they also identified the same
pesticides in the honey bees which forage on the same crop species. By
applying a sophisticated analytical technique using High Performance
Liquid Chromatography (HPLC) coupled to tandem Mass Spectrometry
(atmospheric pressure chemical ionization-mass spectrometry or
APCI-MS/MS), French scientists were able to precisely measure low
amounts of imidacloprid in the soils, plants (leaves and flowers), and
pollens. Extraction, separation, and detection were performed
according to quality assurance criteria.

It's obvious that EPA-OPP should be quite concerned with the fact that
neonicotinoid compounds share specific characteristics under the
following categories that combine to increase their sublethal effects
in honey bees and EPA-OPP has failed to perform a comprehensive
evaluation of these combined characteristics that have been
devastating American honey bee colonies in recent years:

1. These neonicotinoid substances and their metabolites are systemic
pesticides.
Systemic neonicotinoid treatments, which target the entire plant, are
probably contaminating all its parts (French team reported average
levels 5-6 ppb), including the flower (reported average levels 5-6
ppb) through translocation from the root system and seeds (Bonmatin et
al., 2003 and 2005). Corn had a reported tassel average of 4 ppb and
the ear averaged 10 ppb. Sunflower and corn pollen contained about 5
ppb imidacloprid after pesticide treatment. Additional French
scientists observed imidacloprid in even higher levels in young
fast-growing plants where they measured 10-20 ppb in upper leaves,
reaching 100-200 ppb in other leaves, 2-3 ppb in pollen, and less than
1.5 ppb in the nectar. It is confirmed today by repeated laboratory
analyses, and the pesticide manufacturer's no longer deny it, that the
specific active substances are present in the nectar and the pollen of
plants coming from neonicotinoid treated seeds and residues in the
soils. Besides, this fact is not ignored in the research on
imidacloprid and fipronil. These substances are thus found in the food
of bees and their brood. See two studies by Bonmatin et al., 2003 and
2005, and two studies by Chauzat et al., 2002 and 2006.

Entomologist Dr. Maryann Frazier's June 26, 2008 testimony at a
Congressional hearing on honey bee colony losses stated: "We are
becoming increasingly concerned that pesticides may affect bees at
sublethal levels, not killing them outright, but rather impairing
their behaviours and their abilities to fight off infections."
Pesticides and metabolites are being identified in pollen she added, a
disturbing finding! In fact, she testified that 46 different
pesticides including six of their metabolites were identified out of
108 pollen samples analyzed. Up to 17 different pesticides were found
in a single sample. Samples contained an average of 5 different
pesticide residues each. One of the most striking points in Dr.
Frazier's testimony is that 97.2% of pollen samples had pesticides and
only three (2.8%) of the 108 pollen samples had no detectable
pesticides [perhaps using a lower detection limit may have found
pesticides at lower trace concentrations]. In 88 wax samples analyzed,
20 different pesticides including two of their metabolites were
identified. As identified in pollen, the most commonly detected
pesticides were fluvalinate, coumaphos, chlorpyrifos, and the
fungicide chlorthalonil, with fluvalinate and coumaphos detected in
100% of the samples. Extraordinary levels of fluvalinate were measured
up to 204 parts per million in the brood nest wax and pollen.

2. These neonicotinoid substances and metabolites are neurotoxic to
insects including honey bees in low concentrations in the low parts
per billion range.
The neonicotinoid substances are powerful insecticides that
irreversibly block the receptor sites for acetylcholine and
neurotransmission in the adult insect or in the larval stage (J. Pest.
Reform, 2001). In very small doses (approximately one part per billion
- ppb) these compounds are able, without killing the insect, to cause
behavioural disturbances (e.g. orientation errors) that could be deadly
for the colony, whose survival relies on the integrity of the ability
of its members. EPA knows that neonicotinoids are a new class of
insecticides since 1992 that specifically act on the central nervous
system of insects (J. Pest. Reform, 2001).

One of imidacloprid's breakdown products, called the Olefine
metabolite, is particularly troubling since it is known to be more
toxic to insects than imidacloprid itself, according to a 1996 study
(Rouchaud et al.). French researchers measured imidacloprid's
metabolites in addition to imidacloprid in 69% of the pollen in
concentrations as low as 1.1 ppb to 5.7 ppb. A serious concern is that
imidacloprid's metabolites have powerful sublethal effects on honey
bees and may act in combination with imidacloprid to induce additive
toxic effects. However, EPA has failed to consider effects of such
metabolites.

3. These neonicotinoid substances and metabolites have greater
neurotoxic effects on honey bees due to genomic vulnerability.
Research on mapping the honey bee genome discovered that its nicotinic
acetylcholine receptor possesses eleven vulnerable subunit members in
its nervous system (Jones et al., 2006). The honey bee possesses more
nicotinic acetylcholine receptors than either the mosquito or the
fruit fly, research has found. In short, the problem for honey bees is
they possess more vulnerable acetylcholine receptors to be blocked by
pesticides like imidacloprid compared to other insects, and from a
theoretical perspective, the honey bee is made more sensitive to
pesticides like imidacloprid and similar neurotoxins.

French scientists led by Dr. Marc Colin (Institut National de la
Recherche Agronomique, INRA) in 1998 videotaped one set of their
experiments on bees exposed to low ppb concentrations of imidacloprid
to demonstrate that the honey bees became too groggy and intoxicated
effectively impairing their short-term memory in smell and
theoretically blocking normal foraging behaviour. After only a few
days, the honey bees exposed to low ppb levels of imidacloprid stopped
feeding and their numbers sharply dropped compared to the control
groups. Dr. Colin compared videotapes of exposed bees and unaffected
control bees to dramatically demonstrate the powerful sublethal
effects of imidacloprid. If the bees stopped their feeding behaviour,
they will quickly die.

4. These neonicotinoid substances are persistent in the environment.
Evidence confirms the environmental persistence of imidacloprid and
fipronil as well as for some of their metabolites. The same applies to
clothianidin and thiamethoxam. Persistence was expected since the
stability of these compounds is necessary for the systemic action
supposed to last for the entire growing period of the plant over
several months. An imidacloprid fact sheet (J. Pest. Reform, 2001)
cited 1993 EPA information on a field test showing the concentration
of this insecticide did not decrease for a year following treatment.
As the pesticides are widely used and may be used on all cereals,
maize, sugar beets, potatoes (as spray), as well as on beetroot,
oilseed rapes or sunflower, for several consecutive years and in a
systematic rotation, it is necessary to study the behavior of the
substances in the soil after several successive years of treatment,
and the possible contamination of untreated flowering crops that have
been grown in a soil being treated for several consecutive years.

5. These neonicotinoid substances and metabolites may act
synergistically with fungicides in complex combinations.
Research at a North Carolina University laboratory found certain
neonicotinoids when combined with specific fungicides acted
synergistically to increase the toxicity to honey bees over 1,000
times (Iwasa et al., 2004). This presents a concern for honey bees
because both neonicotinoids and fungicides (Terraguard and Procure)
are used rather widely.

Due to the archaic science and theories being applied at the agency,
the EPA Office of Pesticides does not even address or investigate the
possible biological effects including sublethal effects of
combinations of pesticides, but synergistic pesticidal effects can no
longer be ignored when complex multiple combinations of toxic
pesticides are being measured in bees wax and pollen without EPA
having a clue as to what adverse effects they may be causing.

6. Honey bees may avoid higher concentrations of neonicotinoids in
plants with pollen and nectar.
Evidence suggests that honey bees have an innate ability to detect
higher concentrations of neonicotinoids in plants and may avoid
feeding on those plants to avoid chemical exposures, which lead Bayer
scientists to conclude there were no effects below 20 ppb (Schmuk et
al., 2001). But the Bayer's studies may not have considered that honey
bees have an innate detection ability to sense the presence of
neonicotinoids above 20 ppb.

7. These neonicotinoid substances carry acute toxicity that is
extremely harmful to bees.
EPA-OPP has identified imidacloprid and clothianidin as highly toxic
to honey bees. According to the EPA Fact Sheet on Clothianidin,
"Clothianidin is highly toxic to honey bees on an acute basis
(LD50>0.439 mg/bee). It has the potential for toxic chronic exposure
to honey bees, as well as other non-target pollinators through the
translocation of clothianidin residues in nectar and pollen. In honey
bees, the affects of this toxic chronic exposure may include lethal
and sublethal effects in the larvae and reproductive effects on the
queen." Seeds are treated with clothianidin in advance or sprayed with
it in the field, and the insecticide can also be blown onto other
crops. The chemical is often sprayed on corn fields during spring
planting to create a protective film on cornfields.

Conclusion ....
The EPA's Office of Pesticide Programs needs to promptly suspend use
of the nicotinyl insecticides until EPA obtains scientific evidence
that sublethal effects do not cause harm to America's honey bees.